PTAB

IPR2017-01986

Huawei Technologies Co Ltd v. Samsung Electronics Co Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Transmitting and Receiving Control Channels By Restricting A Set of the Control Channels in a Wireless Communication System
  • Brief Description: The ’195 patent discloses methods and apparatuses for a terminal in a wireless communication system (e.g., LTE) to reduce power consumption and complexity. This is achieved by restricting the number of control channels the terminal must monitor for scheduling grants, where the specific subset of channels to monitor is determined based on an identifier of the terminal.

3. Grounds for Unpatentability

Ground 1: Obviousness over Patabandi and R1-071611

  • Claims Challenged: 9-12, 14-15, 25-28, and 30-31 are obvious over Patabandi in view of R1-071611.
  • Prior Art Relied Upon: Patabandi (Patent 7,912,471) and R1-071611 (a 3GPP Contribution).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Patabandi taught the core concept of the ’195 patent: a terminal in an LTE system restricting the control channels it monitors by selecting a subset of available channels based on its identifier (ID) to receive scheduling grants. However, Patabandi provided a general architecture. Petitioner asserted that R1-071611, which summarized 3GPP members' consensus on LTE downlink control signaling, supplied the missing details. Specifically, R1-071611 disclosed that control channels are formed "in a structured way by aggregating 1, 2, 4, or 8 control channel elements" (CCEs) transmitted over OFDM symbols, directly mapping to limitations in independent claims 9 and 25. Dependent claims reciting specific numbers of CCEs (e.g., a maximum of six, a minimum of two) were allegedly taught by proposals from Texas Instruments and Motorola summarized within R1-071611.
    • Motivation to Combine: A POSITA would combine these references because Patabandi disclosed a general control signaling architecture for LTE, and R1-071611 provided the specific, industry-agreed implementation details for the control channels within that architecture. Further, Petitioner argued that Patabandi proposed a solution (using a terminal ID to select a channel subset) to a known problem that R1-071611 identified—the need to restrict the number of control channels a terminal must monitor to reduce complexity.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references because it involved applying a known channel restriction technique (Patabandi) to a standardized channel structure (R1-071611) within the same field of art (LTE control signaling) to achieve the predictable result of reduced monitoring complexity.

Ground 2: Obviousness over Patabandi and R1-071216

  • Claims Challenged: 9-12, 14-15, 25-28, and 30-31 are obvious over Patabandi in view of R1-071216.
  • Prior Art Relied Upon: Patabandi (Patent 7,912,471) and R1-071216 (a 3GPP Contribution).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to the R1-071611 combination. Petitioner contended that Patabandi taught the primary concept of ID-based channel subset selection. The secondary reference, R1-071216, was a 3GPP proposal that also disclosed forming control channels by aggregating CCEs (providing an illustrative example of 1, 2, or 3 CCEs). Critically, R1-071216 explicitly proposed that for large bandwidths, a terminal can be configured to monitor only a subset of the control channel elements to maintain modest complexity.
    • Motivation to Combine: A POSITA would combine the references because R1-071216 identified a specific problem (high UE complexity in large bandwidth systems) and proposed a general solution (monitoring a subset of channels). Patabandi disclosed a specific, well-understood method for implementing that solution (selecting the subset based on the terminal's ID, a time parameter, and/or a random element). Therefore, a POSITA would be motivated to apply Patabandi's specific selection method to solve the exact problem outlined in R1-071216.

Ground 3: Obviousness over Patabandi, a 3GPP Reference, and Ghosh

  • Claims Challenged: 14-15 and 30-31 are obvious over Patabandi in view of any of R1-071611, R1-071216, or R1-071223, and further in view of Ghosh.

  • Prior Art Relied Upon: Patabandi (Patent 7,912,471), one of R1-071611, R1-071216, or R1-071223 (3GPP Contributions), and Ghosh (Application # 2005/0250497).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground specifically targeted claims 14 and 30, which require determining the set of control channel candidates using a "random number generation function" that uses the terminal ID as a variable. While Patabandi suggested using random elements and a UE identifier, Petitioner introduced Ghosh to strengthen this teaching. Ghosh explicitly disclosed using a hashing function (which Petitioner argued a POSITA would understand as a type of random number generation function) that takes a UE identifier and a frame number as inputs to allocate control channel resources.
    • Motivation to Combine: Petitioner argued that Patabandi identified a potential problem of collision when multiple terminals are allocated the same resources. A POSITA, seeking to solve this known problem, would have been motivated to incorporate the teachings of Ghosh. Ghosh provided a known technique—using a hashing function with a UE identifier—to flexibly allocate resources and avoid collisions. This technique was already used in WCDMA (the predecessor to LTE) and would have been a natural and predictable solution to apply in the LTE framework described by Patabandi and the 3GPP references.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Patabandi in view of the 3GPP contribution R1-071223, but relied on similar design modification theories as presented for R1-071611 and R1-071216.

4. Key Claim Construction Positions

  • "a set of control channel candidates": Petitioner noted that in co-pending litigation, it argued this term means "all available control channels transmittable by a base station," while the Patent Owner argued it means "necessarily less than all transmittable control channels." For the IPR, Petitioner requested that the Board find the term includes any set of transmittable control channels or that it needs no construction.
  • "each control channel candidate ... consists of one of one, two, four, and eight ... CCEs": Petitioner noted the Patent Owner's litigation position that this term is satisfied even if candidates consist of other numbers (e.g., 1, 2, or 3 CCEs). Petitioner asserted that the challenged claims were unpatentable under either interpretation and that the Board need not resolve the issue.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 9-12, 14-15, 25-28, and 30-31 of Patent 8,315,195 as unpatentable.